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Step 1
Hire your expert prior to beginning discovery so he or she can assist you with strategy and tactics. The expert should be able to tell you the strengths and weakness of claims for emotional distress and what role(s) the expert could take in the litigation, e.g., be a consultant expert and/or expert witness or even help with constructing a foundation for Frye or Daubert motions.
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Step 2
After your expert has reviewed relevant documents ask her to develop lines of questioning for opposing parties and experts. Determine whether or not your expert should evaluate the plaintiff and should be named as an expert witness in the case. These are important strategical and tactical elements that should be considered within the context of the entire case.
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Step 3
Make time to work with your expert in understanding his work and the foundation of his opinions. Especially important is a meeting to go over the direct and cross examinations if she is to testify as an expert witness or rebuttal expert.












